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Income Tax Appellate Tribunal, DELHI BENCH ‘G’, NEW DELHI
Before: Sh. Sudhanshu SrivastavaDr. B. R. R. Kumar
Per Dr. B. R. R. Kumar, Accountant Member:
The present appeal has been filed by the revenue against the order of the ld. CIT(A)-38, Delhi dated 23.02.2017.
Following grounds have been raised by the revenue:
1. Whether on the facts and circumstances of the case, the ld. CIT(A) erred in directing the AO to exclude the interest amount of Rs.89,20,96,179/- from the interest not directly attributable to any particular income or receipt while computing disallowance u/s 14A r.w.r. 8D.”
The dividend earned by the assessee was Rs.1,91,577/-. The amount disallowed by the AO was Rs.3,65,20,080/-.
2 Helios Photo Voltaic Ltd. 4. Out of which, the ld. CIT (A) has directed to exclude the interest amount of Rs.89.20 Cr. which was not attributed to earning of exempt income.
We find that the ground taken up by the revenue has no legal validity as the ld. CIT (A) has rightly directed to exclude the interest income on the amounts involved in investment and in the overseas companies which did not give rise to any exempt income and which was not utilized for earning the exempt income.
In the result, the appeal of the revenue is dismissed. Order Pronounced in the Open Court on 17/02/2021.